GR 101332; (March, 1996) (Digest)
G.R. No. 101332 March 13, 1996
PEOPLE OF THE PHILIPPINES, plaintiff-appellee, vs. CLARO BERNAL, MANUEL BERNAL and RAMON BERNAL, accused-appellants.
FACTS
The prosecution established that on November 27, 1988, in Bacacay, Albay, the Bernal brothers—Claro, Manuel, and Ramon—attacked Vicente Barrameda at a store. Eyewitnesses, including the victim’s wife Luisa and Salvador Barcelona, testified that Claro initiated the assault by hacking Vicente on the head with a bolo. As Vicente fell and tried to crawl away, Ramon stabbed him with a bamboo spear on the chest, and Manuel delivered additional bolo blows. The attack resulted in Vicente sustaining forty-six wounds, leading to his death from hypovolemic shock. Luisa, who tried to shield her husband, also suffered a hand injury.
The defense presented a contradictory account. Accused Claro Bernal claimed self-defense, alleging that Vicente attacked him first with a stool, prompting him to retaliate with a bamboo stick and later a bolo. He asserted his brothers were not present. Manuel and Ramon interposed alibi, claiming they were elsewhere during the incident—Manuel at a farm six kilometers away and Ramon at a basketball court.
ISSUE
Whether the guilt of the accused-appellants for the crime of murder was proven beyond reasonable doubt.
RULING
Yes, the Supreme Court affirmed the conviction. The Court found the prosecution’s evidence, provided by credible eyewitnesses who gave consistent and categorical testimonies, to be strong and convincing. Their positive identification of all three appellants as direct participants in the concerted attack prevailed over the defenses raised. Claro Bernal’s claim of self-defense was untenable. The nature, number, and severity of the victim’s wounds—forty-six in total, inflicted by multiple weapons—were grossly disproportionate to any purported aggression from an unarmed victim and indicated a determined effort to kill, negating self-defense. The alibis of Manuel and Ramon were likewise rejected for being weak and unsubstantiated; they failed to prove it was physically impossible for them to have been at the crime scene. The qualifying circumstance of treachery was correctly appreciated, as the sudden and unexpected commencement of the assault by Claro, without any provocation, effectively deprived Vicente of any opportunity to defend himself. The Court modified the civil indemnity, awarding P50,000.00 to the heirs and P4,000.00 for proven funeral expenses.